One of the questions that practitioners ponder is how to properly discount the value of stock in a closely held C corporation to reflect the future income tax liability on the corporation's unrealized built-in gains (BIGs). For transfer-tax...
You might think of the gift tax as the lesser of two evils for transferring wealth, with the other evil being the estate tax. Certainly, it can be cheaper to pay gift tax rather than estate tax, because of the gift tax's nature.1 But always...
In a bull market, one of the best ways to transfer wealth is by a sale to a grantor trust. Little wonder that it's been so popular for the past 20 years. But a net gift coupled with a loan for the gift tax can transfer more wealth and at a faster...
Next year, no matter how preoccupied the federal government is and no matter who is president, a new federal estate tax law is quite likely to be adopted. If it isn't, on Jan. 1, 2010, the U.S. federal estate tax will disappear at least for...
Robert Craig Knievel, purportedly nicknamed by police after an arrest for stealing hubcaps off cars, was born on Oct. 17, 1938 in Butte, Mont., and died in Clearwater, Fla., on Nov. 20, 2007, at the age of 69. His will, recently made available to...
Multi-participant trusts1 have become immensely popular. These trusts replace the single, all-powerful trustee with a host of independent decisionmakers, all deriving their authority directly from the trust instrument. At first, we saw multi...
The model for a managing directed trustee (MDT) comes from organizations like family offices and private trust companies (PTCs) that evolved, in part, to support and coordinate a family's trustees and other financial services providers. Family...
My message is not for the easily offended, but, in the closing months of 2008, I feel this must be said: Congress still has not done anything about the estate tax law. If Congress doesn't act very soon, each one of us should ask ourselves: If we...
The Internal Revenue Service has almost literally thrown the (Internal Revenue Code) book at family limited partnerships (FLPs), seeking to negate their validity, and thereby knock out discounts and reap higher tax payments. It has had some of its...
The intention behind incentive trusts is excellent; the rigidity of these trusts is not. It's time to ditch the inflexible incentive trusts and instead learn how to fashion a principle trust. Rather than strict rules for distributions, a principle...
